Tapping Into the Organic MarketBy Tracy Hewitt, Ph.D.
Have you ever thought about using organic ingredients in your products? According to the U.S. Department of Agriculture's (USDA) Economic Research Service's Economic Information Bulletin Number 58, Marketing U.S. Organic Foods: Recent Trends From Farms to Consumers, "The organic meat sector is still in early stages of development, and has relatively low total sales. Yet the sector is currently one of the fastest growing in the organic industry, with total retail sales having increased by a factor of 46 between 1997 and 2007. Poultry accounted for 59 percent and beef made up 24 percent of the 2007 sales of $476 million. Egg sales have grown at a slower rate between 1997 and 2007, although the average annual growth rate was 19 percent over these years."

If you do decide to tap into the organic market, there are a few things you must remember. Organic meat begins with the animal's production and its feed. Organic meats are derived from livestock and poultry that are certified as "organic." The USDA organic seal verifies that producers provided living conditions that accommodate the natural behavior of the animals, including year-round access to the outdoors. The seal also certifies that producers did not use antibiotics or growth hormones and used 100% organic feed.

Meat, poultry, and other types of agricultural products that are sold, labeled, or represented as organic must be produced and processed in accordance with the standards developed by the National Organic Program (NOP), a marketing program within the USDA's Agricultural Marketing Service (AMS). The organic standards describe the specific requirements that must be verified by a USDA-accredited certifying agent before products can be labeled USDA organic.

Except for operations with a gross income from organic sales totaling $5,000 or less, farm and processing operations that grow and process organic agricultural products must be certified by USDA-accredited certifying agents. USDA conducts audits and ensures that the more than 90 organic certification agencies operating around the world are properly certifying organic products. In addition, USDA conducts investigations and enforcement activities to ensure that all products labeled as organic meet the requirements of the USDA organic regulations. A civil penalty of up to $11,000 can be levied on any person who knowingly sells or labels a product as organic that is not produced and handled in accordance with NOP's regulations. NOP's regulations are contained in Title 7 of the Code of Federal Regulations, Part 205 (7 CFR Part 205). These regulations may be accessed at www.gpo.gov/fdsys/pkg/CFR-2011-title7-vol3/pdf/CFR-2011-title7-vol3part205.pdf.

Once you have decided to use organic ingredients in your products, it is important to understand the proper use of organic claims on labels. NOP's labeling requirements apply to raw, fresh, and processed products that contain organic agricultural ingredients. To claim "organic" on a product's label, the product must contain at least 95 percent organic ingredients, not including added water and salt. The remaining 5 percent of the product's ingredients must be organically produced, unless they are not commercially available in organic form or adhere to a preapproved list of substances recorded in the organic regulations. These preapproved substances have been deemed acceptable in organic foods based on specific criteria that addresses the actual need for the substance and its impact on human health and the environment.

If you want to claim "100% organic," your product must contain only 100% organically produced ingredients and processing aids, not including added water and salt.

Labeling requirements for "100% organic" and "organic" products indicate that product packages must identify each organic ingredient in the ingredient statement (with the exception of water and salt) and the handler or distributor of the product, preceded by the statement "certified organic by [name of certifier]." Optionally, the USDA organic seal and the seal or mark of the certifying agents may appear on "100% organic" and "organic" product packages and in advertisements.

When "made with organic ingredients" is on a label, it indicates that a product contains at least 70 percent organic ingredients, not including added water and salt. The product may contain up to 30 percent of non-organically produced agricultural ingredients and/or other substances, including yeast, allowed by 7 CFR 205.605. Along with the phrase, "made with organic ingredients," the package label may list up to three of the organic ingredients or food groups on the principal display panel.

Like products that are labeled as "organic" or "100% organic," products certified as "made with organic ingredients" must have an ingredients statement that lists the organic ingredients as "organic" when other organic labeling is shown. Water and salt should not be identified as "organic." The statement "certified organic by _______" or a similar statement followed by the name of the certifying agent must be placed below the name and address of the handler, bottler, distributor, importer, manufacturer, packer, processor, etc., of the finished product. However, products labeled "made with organic ingredients" may not have the USDA organic seal anywhere on the package.

If you want to make the claim, "some organic ingredients," for a product containing less than the 70 percent threshold, you have the option of identifying each organically produced ingredient in the ingredient statement and displaying the product's percentage of organic contents on the information panel. Water and salt included as ingredients cannot be identified as organic. Additionally, the label must not show any other reference to organic contents, the USDA organic seal, or the certifying agent seal.

For more information on NOP and organic labeling, visit AMS' Web site at www.ams.usda.gov/nop. You may also contact NOP by calling (202) 720-3252 or writing to:
National Organic Program
AMS, U.S. Department of Agriculture
Room 2646, South Building
1400 Independence Avenue, SW, Mail Stop 0268
Washington, DC 20250

Visible Contamination at the Final Wash: Is It Ever Okay?By Jane Johnson, DVM
For those of you involved in slaughter operations, there may have been times when you wondered, "are there any circumstances when livestock or poultry with visible contaminants (e.g., hairs, dirt specks, rail dust, ingesta) may enter a wash cabinet?"

According to askFSIS, the agency recognizes that incidental visible contamination is unavoidable in the slaughter dressing operation, and there is no predetermined acceptable size or number of contamination events. However, such events should be rare occurrences because contamination is a preventable food safety hazard. Contamination is expected to be prevented at all steps in the slaughter dressing operation, and you're expected to prevent repeated occurrences of visible contamination. Your plant's Sanitation Standard Operating Procedures (SSOP) must be designed and implemented to remain effective in preventing contamination or adulteration.

Sanitary dressing procedures should:

Identify the points in your operation where contamination can occur;

Describe the procedures your plant will take to prevent contamination from occurring;

Describe the procedures for what constitutes compliance/noncompliance at each point:

If you incorporate a carcass wash cabinet as part of your sanitary dressing procedure, the operation of the wash cabinet cannot create an insanitary condition by redistributing unavoidable contamination on the carcass or adjacent carcasses. You must ensure that you have in place hygienic measures to minimize the presence of visible contamination before the carcasses or parts enter the wash unit. It is inconsistent with the requirements of 9 CFR 416.1 to allow contamination to occur and then simply remove or dilute out the contaminant (e.g., by using a carcass wash cabinet). It is your responsibility to support your determination that allowing carcasses with incidental contamination (e.g., hairs, specs, rail dust) to enter a wash cabinet does not create a food safety hazard or create an insanitary condition.

A prudent plant will have written procedures for sanitary dressing as a means to describe how contamination will be prevented to the maximum degree practical and to provide the greatest assurance of meeting the regulatory requirements of 9 CFR 416. By having a written program, your plant is capable of evaluating both "real time" and "after the fact" results when determining if the program was implemented as intended. A written program is a more optimal means of demonstrating that your plant is effectively preventing contamination than an undocumented system and is especially important when you compare your plant's sanitary dressing practices to your plant's pathogen control performance documentation.

For additional information, see the askFSIS Q & A titled, FSIS Directive 6410.1-Visible Contamination, or contact the Small Plant Help Desk at 1-877-FSISHelp (877-374-7435) or InfoSource@fsis.usda.gov.

Commonly Asked Questions & AnswersQ.Can the required nutrition facts panel be added with a sticker label or insert label as a permanent solution to being compliant?

A.Yes. A nutrition facts panel can be added as a sticker or insert.

Q.Can an establishment generically add coupons to previously approved labeling or will this change require resubmitting the label for another sketch approval?

A.Yes. The addition of coupons can be approved generically in accordance with 9 CFR 317.5(b)(9)(vi) or 381.133(b)(9)(vi).

Q.Can nutrition facts for single-ingredient products be presented as raw or cooked on labels or point-of-purchase materials? If cooked, what is the correct description to use from the USDA National Nutrient Database for Standard Reference (i.e., broiled, braised, or roasted)?

A.Point-of-purchase (POP) materials for non-ground single-ingredient raw products can be based on nutrition information for raw or cooked products. If retailers provide nutrition information for the product as cooked, a cooking method that does not add any nutrients to the product must be used and the method must be indicated on the POP materials. However, if a nutrition claim is made on the POP materials, all of the format and content requirements of 9 CFR 317.309 apply. If only nutrition information — and not a nutrition claim — is supplied on POP materials, the requirements of 9 CFR 317.309 apply, but (i) the listing of percent Daily Value for nutrients (except vitamins and minerals in 9 CFR 317.309(c)(8)) and footnote required by 9 CFR 317.309(d)(9) may be omitted, and (ii) the POP materials are not subject to any of the format requirements.

Q.Are "major cuts" that are marinated required to have nutrition labeling?

A.It depends on where they are marinated. Nutrition labeling is not required for the major cuts of meat or poultry products marinated at the store (9 CFR 317.400(a)(7)(ii) and 381.500(a)(7)(ii)). If the meat and poultry products come to the store already marinated, packaged, and labeled for the consumer, they require nutrition information, unless the supplier qualifies for the small business exemption on that product.

A.Yes, as long as there are no nutrition information or nutrient content claims on the labeling.

Q.Regarding meatloaf meat, if the ground pork and ground beef are in separate portions on the same tray, could the package have two nutrition labels, one for the ground beef and one for the ground pork?

A.Yes. If the ground beef and ground pork were separate, there could be two nutrition facts panels.

Q.Should the definition of the "major cuts" in 9 CFR 317.344 and 381.444 be interpreted to include boneless fillets, tenderloins, thigh meat, etc., or does it strictly include bone-in product only?

A.Major cuts could include both bone-in or boneless meat or poultry since nutrition information is based on the edible portion of the product. It does not matter if the product is boneless or bone-in; the same product would require the same nutrition information on the raw 4-ounce edible portion or cooked 3-ounce edible portion.